Trade Compliance
Guides & Insights

Indonesia began imposing safeguard duties on imported cotton woven fabrics on January 10, 2026. The regulation, signed December 22, 2025, adds a new layer of cost for textile exporters shipping to Indonesia — on top of existing MFN rates and any preferential tariffs you might already be paying.

A shipment of electric motors sat in a bonded warehouse outside Los Angeles for 47 days last fall. The importer had documentation — bills of lading, commercial invoices, supplier certificates. What they didn't have was traceability below Tier 1.

A semiconductor equipment distributor in San Jose shipped deposition tools to a long-standing customer in Shenzhen last spring. Routine transaction. Same buyer they'd worked with for eight years. Except the buyer's parent company had landed on the Entity List two weeks prior.

A precision instrument manufacturer in Ohio shipped accelerometer test equipment to a German partner last spring. The export compliance manager classified it under EAR, ran standard BIS screening, filed normal commercial documentation. Three weeks later, two FBI agents walked into the front office asking questions.

Your VP of Engineering hires a brilliant semiconductor designer. PhD from Tsinghua, ten years at TSMC, exactly the expertise you need. HR processes the H-1B. IT sets up the workstation. Engineering gives them access to the design files. Nobody calls compliance.

Your CFO asks a simple question: "Our German subsidiary makes a product and ships it to Singapore. Why does US export control even apply?" Because the circuit board has a US-origin chip.

Your compliance team tells you license exceptions are handled. They've been shipping under TMP, LVS, RPL for years. Process is solid. Everything's documented. Then BIS sends a records request.

OFAC's maximum civil penalty under IEEPA reached $377,700 per violation as of January 15, 2025. For a mid-sized exporter with 15 shipments to a screening-missed party, exposure crosses $5.6M before transaction value multipliers kick in. Voluntary self-disclosure cuts that base penalty in half—but only if the filing arrives at Treasury before anyone else reports the violation.

Cadence Design Systems paid $140 million in combined penalties after a July 2025 settlement revealed years of deficient export compliance records. When the Office of Export Enforcement sends a request letter, the 5-year retention clock under 15 CFR 762 becomes your operational reality, and gaps in your documentation trail become immediate liabilities.